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RE: Current Status of Grand Central Sanitary Landfill, Inc. Slate Belt Heat Recovery
Center Preliminary Land Development/Major Subdivision Plan
As requested, I have prepared this letter detailing the current status of the Grand Central
Sanitary Landfill, Inc. Slate Belt Heat Recovery Center Preliminary Land
Development/Major Subdivision Plan.
The Plan is entitled "Major Subdivision and Preliminary Land Development Plan for
Slate Belt Heat Recovery Facility" for lands owned by Grand Central Sanitary Landfill, Inc. and
prepared for Slate Belt Heat Recovery Center, LLC, Green Knight Economic Development
Corporation (GKEDC), and Grand Central Sanitary Landfill, Inc. (GCSL), Sheets 1 through 23
of23, dated February 6,2018 last revised August 13,2019 (and actually received by the
Township Municipal Office on August 30, 2019), prepared by EarthRes Group, Inc. The
proposed facility shall be referred to as the "Site," "Facility," or "SBHRC".
This letter identifies the defects found in the plan submission as identified in the most
recent Plainfield Township expert review letters, which are listed as follows:
4. Hanover Engineering, Inc. Robert Lynn Letter Dated July 11, 2019;
The identified items that are currently deficient are provided as follows:
A. A formal review for compliance with the Code of Ordinances of Plainfield Township has
been performed. The following sections of the Township Zoning Ordinance (Chapter 27),
Subdivision and Land Development Ordinance (SALDO) (Chapter 22), and Stormwater
Management Ordinance (Chapter 23), have not been complied with by the Applicant.
1. Chapter 27 - Zoning
a.Section §27-316 (2) (II) - Upon a review of the revised plan sheets C-03,
C-17, C-18 and Truck Turn Exhibits C-04 and C-05, it is the opinion of
the Zoning Officer and the Township Manager that a Variance is still
required from Section §27-316 (2) (II) (2) of the Code of Ordinances of
Plainfield Township due to the fact that the proposed entrance and exit to
the facility are not located along an Arterial or Collector Road. Pursuant to
the requirements set forth in §27-316 (2) (II) (2), the proposed entrance
and exit to the facility are not located along either an Arterial or Collector
road. The proposed entrance and exit to the facility are located along an
interior Private Access Drive of the Grand Central Sanitary Landfill.
The entrance and exit to the facility of the proposed "Pen Argyl Road
(S.R. 1011) Low-Volume Driveway" are now separated and clearly
designated. Further, the proposed entrance and exit to the facility are each
at least thirty feet (30') in width.
a.Section §22-108 (2) (3) - Actual legal, engineering, and other costs and
expenses incurred by the Township, in connection with the review and
processing of a subdivision or any proposed land development, shall be
reimbursed to the Township by the subdivider or developer. No final plan
shall be approved unless all fees and charges have been paid in full. As of
September 6, 2019, a combined total of $21,887.02 in actual legal,
engineering, and other costs and expenses incurred by the Township in
connection with the review and processing of the above-referenced
SBHRC Land Development/Major Subdivision plan remain unpaid.
Therefore, the Applicant has failed to comply with this provision.
b.Section §22-503 (1) (A) (6) - Sanitary sewer profiles shall be provided.
Evidence of Pen Argyl Municipal Authority review and approval of
the sanitary system design and details have not been provided, as
requested by the Township Engineer. Therefore, the Applicant has
failed to comply with this provision.
c. Section §22-503 (1) (A) (7) - Evidence of PA American Water Company
review and approval of water system design and details shall be provided.
The review and approval of water system design and details have not
been provided, as requested by the Township Engineer. Therefore, the
Applicant has failed to comply with this provision.
d.Section §22-503 (8) (A) - Evidence of Erosion and Sedimentation Control
Plan approval by Northampton County Conservation District shall be
provided. The requested evidence of review and approved has not been
provided with the latest plan review application; the Applicant has
failed to comply with this provision.
Further, the September 6,2019 letter of Jason Smith indicates that the
Applicant has labeled Sedimentation Basin No.2 as "waters of the
Commonwealth" on Plan Sheets C-04A and CO-OS; however, there
remains a discrepancy on the regulatory boundary of this water feature, as
noted above.
a. Section §27-41O (1) (A) and (B) of the Code of Ordinances of Plainfield
Township.
Defmitions:
Applicant - Grand Central Sanitary Landfill, Inc., Synagro Technologies, Inc., and Slate Belt
Heat Recovery Center, LLC.
Operator - the organization that operates the Slate Belt Heat Recovery Center biosolids
processing facility and all of its accompanying accessory uses. Slate Belt Heat Recovery Center,
LLC is the current Operator known to the Township; the term Operator shall apply to any
successor organization that operates the Slate Belt Heat Recovery Center biosolids processing
facility and its accompanying accessory uses.
NMCP - The Nuisance Mitigation Control Plan as approved by the Township and the Applicant.
Record - Shall include any transcripts, testimony, exhibits, review letters, expert reports, and
submissions made by the Township and the Applicant, as well as any information provided
during the course of the public meetings, each being given their appropriate weight.
Site - Leasehold interest of Slate Belt Heat Recovery, LLC for the SBHRC, as shown on the
approved Final Development Plan.
Lot - The parcel of land delineated, as shown on the approved Final Development, Sheet C-04 of
the Lot Line Adjustment Plan.
Facility - The building, infrastructure, plant, equipment and services that include the industrial
biosolids processing facility use known as the Slate Belt Heat Recovery Center. The land use is
defined locally within §27-202 of the Code of Ordinances of Plainfield Township as a "Material
Separation Facility".
b. As a condition of Final Land Development approval, the Final Plan shall depict/state on
the sheet to be recorded that the specific use classification for the use approved for the
Site is a Material Separation Facility, with approved accessory uses and no other uses,
e. As a condition of Final Land Development approval, the Applicant shall obtain letters
from GCSL and GKEDC agreeing to the Final Plan and conditions.
h. As a condition of Final Land Development approval, no direct retail sales to the public
shall be conducted at the Site, including the sale of fuel pellets or fertilizer pellets.
1. As a condition of Final Land Development approval, all uses accessory to the Material
Separation Facility Use, shall cease to be operated within six (6) months of the date that
the Material Separation Facility Use permanently ceases operations at the Site.
m. As a condition of Final Land Development approval, all required Federal and local
permits shall be obtained and proof of issuance shall be provided to the Township.
n. As a condition of Final Land Development approval, the Applicant and/or Operator of the
proposed Facility will comply with all applicable local, state and federal regulations
related to the Facility or the Site.
o. As a condition of Final Land Development approval, all required road or access driveway
improvements shall be completed prior to the commencement of Material Separation
and/or biosolids processing operations at the Facility or the operation of any accessory
use on the Site.
t. As a condition of Final Land Development approval, the Applicant and/or Operator shall
take no action related to the Facility or the Site which prevents or impedes compliance
with the terms of the area more fully described within the recorded Easement Agreement
between Grand Central Sanitary Landfill, Inc. and Plainfield Township dated March 12,
1997, and shall provide with sixty (60) days advance written notice of any proposed
changes to the Facility or the Site, which shall include but not be limited to construction
activities related to the Facility or the Site, realignment of the Access Drive, and the
placement of any structures related to the Facility or the Site, which might affect the
Easement Agreement Area in any manner.
u. As a condition of Final Land Development approval, all comments of the Fire Chief of
the Plainfield Township Fire Company and the Emergency Management Coordinator
related to the Facility or the Site shall be addressed by the Applicant and the Operator.
v. As a condition of Final Land Development approval, all access roads associated with the
proposed Facility or Site shall be paved.
aa. As a condition of Final Land Development approval, the Applicant/Operator shall submit
a will serve letter from Pennsylvania American Water Co.
dd. As a condition of Final Land Development approval, the Applicant shall provide on the
Final Plan, all relevant details or specifications of the proposed water quality swale or
conveyance for stormwater management at the Site, including, but not limited to, design,
size, cross-sections, outlet design, capacity and volume calculations, and proposed
plantings.
ee. As a condition of Final Land Development approval, the Applicant and/or Operator shall
place a description on the Final Plan regarding how each and every permanent or
temporary BMP on or associated with the Site shall be operated and maintained, and the
identity of any entities responsible for the operation and maintenance of such BMPs. The
Applicant and/or Operator shall notify the Township in writing 30 days in advance of
making any changes reflected in the Final Plan.
ff. As a condition of final Land Development approval, the Applicant and/or Operator shall
allow entry and inspection of the Facility or the Site by any authorized representative of
the Township who has the appropriate personal protection equipment and who has
received appropriate safety instruction during regular business hours, or at any time the
Facility is operating if advance notice of at least 4 hours is provided.
gg. As a condition of Final Land Development approval, the Applicant/Operator shall include
all details related to Facility or Site traffic management including, but not limited to,
signs, barriers, and pavement markers, on the Final Plan. The Applicant and/or the
Operator shall not permit left hand turns into the eastern access drive of the Site from the
Route 512 Access Road.
hh. As a condition of Final Land Development approval a fence around Sedimentation Basin
#2 shall be provided for safety purposes, and to prevent unauthorized access to
Sedimentation Basin #2, if determined necessary by the Plainfield Township Board of
Supervisors, in their sole discretion.
11. As a condition of Final Land Development approval, the Applicant and/or Operator shall
provide certified or verified as-built drawings, in a form acceptable to the Township
Engineer, for every significant alteration or modification to Sedimentation Basin #2
related to the Facility or the Site.
JJ. As a condition of Final Land Development approval, the Applicant and/or Operator shall
provide a schedule of Site inspections during construction on the Final Plan. The Final
Plan shall indicate that no earth-moving activities related to the Facility or the Site may
commence prior to a mandatory pre-construction meeting, which meeting shall include a
representative from the Township, and representatives of the appropriate regulatory
agencies.
SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 16
kk. A Final Land Development condition shall be that the Applicant and/or Operator shall
provide notice in writing and 30 days in advance of any fill to be placed into
Sedimentation Basin #2.
a. As a condition of Final Land Development Approval, the Applicant shall comply with
Section §27-316 (2) (II) (2) of the Code of Ordinances of Plainfield Township;
alternatively, the Applicant shall obtain a Variance and/or obtain favorable zoning relief
from Section §27-316 (2) (II) (2) of the Code of Ordinances of Plainfield Township,
which reads as follows: "Entrances and exits to the facility shall be separated and clearly
designated; entrances and exits shall each be at least 30 feet in width and shall be located
along either an arterial or collector road."
b. As a condition of Final Land Development Approval, the Applicant shall comply with
Section §27-505 of the Code of Ordinances of Plainfield Township; alternatively, the
Applicant shall obtain a Variance and/or obtain favorable zoning relief from Section §27-
505 of the Code of Ordinances of Plainfield Township, which reads as follows: "All areas
within 50 feet of the banks of any stream, lake, or pond shall be in open space."
d. As a condition of Final Land Development approval, the Applicant and Operator shall
limit the capacity of the Facility to treat or dispose of solid wastelbiosolids to a daily
maximum amount of 400 wet tons per day.
e. As a condition of Final Land Development approval, the Applicant and/or Operator shall
retain or submit promptly to the Township and PA DEP, as required by the Groundwater,
Stormwater and Biosolids Monitoring Plan, or any components thereof, and applicable
permits related to the Facility or the Site, copies of any surface water or ground water
sample analyses obtained by Applicant and/or the Operator, and any of their
representatives or consultants related to the Facility or the Site. The current list of
sampling requirements in the NMCP and in the PA DEP regulations will be determined
subsequently as part of the PA DEP General Permit review process, as per the Applicant.
SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 17
f. As a condition of Final Land Development approval, and prior to issuance of a zoning
permit or building, Applicant or the Operator shall perform or provide the following,
which is necessary to determine whether the proposed use compromises the public health,
safety, and welfare or causes the adverse environmental impacts as listed in §27-41O (1)
(A) and (B) of the Township Code of Ordinances.
In order to provide the necessary information to the Board of Supervisors to assist the
governing body with making the determination as to whether the proposed use
compromises the public health, safety, and welfare, the adverse environmental impacts as
listed within §27-410 (1) (A) and (B) shall be reviewed locally in accordance with the
following standards:
2. Determine whether and to what degree the effects or impacts will infringe
unreasonably upon or violate the protected rights and values (air. water, scenic,
historical, natural, and esthetic) or unreasonably cause actual or likely
deterioration ofthe listed values; and
3. Unless the unreasonable effects or impacts ofall activities associated with the
proposed use can be eliminated, or reduced to a level where the impacts are not
unreasonable, then the use cannot be permitted, pursuant to the requirements of
§27-410 (1) (A) and (B).
Please call me or email me if you have any questions or require additional information regarding
this matter.
Thomas R. Petrucci
Township Manager/Secretary
Alternate Zoning Officer
Phone: 610-759-6944 ext 102
Email- manager@plainfieldtownship.org
TRP:trp
September 4, 2019
Dear Tom:
As a follow up to your August 21, 2019 email, below please find our comments related to Peter
Spissak (Traffic Planning & Design, Inc.) August 19, 2019 email with Brian Boyer (PennDOT 5-
0 Permit Unit) and revised plans C-03, C-15, and C-17 prepared by EarthRes Engineering last
revised 8/13/19 which you provided with your email.
1. Plan sheet C-03 depicts a 74 foot wide driveway with what appears to be a pavement
marking at the center of the driveway. The driveway has a fifty foot deep throat length.
Brian Boyer confirms Peter Spissak’s August 19, 2019 email in which Brian indicates
that the proposed driveway would ultimately be approved given the following PennDOT
requirements:
A. Confirmation that adequate sight distance can be provided at the
intersection
B. The driveway would have a maximum width of 24 feet
C. The driveway radii would be 15 to 20 feet.
D. The applicant would provide as much shoulder widening as possible
without impacting the exiting utility poles for up to 200 feet in either
direction from the driveway along Pen Argyl Road.
The driveway depicted on C-03 may satisfy item A above, however it does not satisfy
items B, C, or D.
Mr. Thomas R. Petrucci, Township Manager
Plainfield Township
Scoping App #S0520190014
Benchmark Project No. 671004 September 4, 2019
2. The email referenced above indicates that approval of the driveway would also need to
address truck restrictions. The plan C-03 indicates truck restriction signs on Pen Argyl
which face the eastbound and westbound Pen Argyl Road through traffic and are located
approximately fifty feet to the east and west of the proposed driveway. It is doubtful that
this is what Brian Boyer intended when he indicated the need for truck restrictions. The
signs would not provide proper notification to trucks on Pen Argyl Road approaching the
new intersection. It is more likely that Brian Boyer intended to limit the trucks using the
proposed driveway in which case a different sign arrangement would be necessary and
signs would be required both within the site and along Pen Argyl Road.
3. A plan should be provided indicating the largest vehicle anticipated to use the proposed
driveway and that vehicles turning path. The plan should also depict whether that vehicle
can be accommodated on the existing pavement at the intersection and what pavement is
proposed to be constructed as part of the proposed driveway. This would also assist in
determining whether item 1.D above is addressed.
Further, we received the August 30, 2019 Earthres Transmittal on September 3, 2019 which
included Truck Turning Exhibits. Sheet C-05 (last revised 8/13/19) which is included in the
Truck Turning Exhibits, indicates the turning movements at a proposed driveway onto Pen
Argyl Road. This plan does not indicate a 24 foot wide driveway as was referenced in the Peter
Spissak August 19, 2019 email to Brian Boyer at PennDOT. The submitted plans depict a
significantly wider driveway which is contrary to the driveway specifications which Brian Boyer
indicated could ultimately be approved by PennDOT. The plan also does not indicate the Pen
Argyl Road shoulder widening which Brian Boyer indicated would be required.
Sincerely,
-2-
Benchmark Civil Engineering Services, Inc. • 1727 Jonathan Street • Allentown, PA 18104 • Phone: (610) 776-6700 • www.bencivil.com
September 5, 2019
Mr. Petrucci:
The following is a summary of comments related to the most recent revision of the Nuisance
Mitigation Control Plan (NMCP) dated August 29, 2019, submitted to the Township by Earthres
on behalf of Synagro. Comments summarized herein are based on the remaining nine comments
outlined in the August 22, 2019 letter from Material Matters to the Township.
Comments acknowledged as resolved in the August 22, 2019 letter from Material Matters are not
included herein and have been removed from the summary. However, the numbering system
used to identify the outstanding comments from the July 10, 2019 comment letter remain. (NOTE:
The pdf page numbers noted in the following narrative are from the August 29 NMCP
submission.)
c. Dust Preventative Monitoring Procedure (pdf page 18) – It is expected that around
a facility generating granular biosolids, there is potential to see dust on the
vegetation and other nearby surfaces. Add an Action Item to conduct visual
inspection of dust on nearby surfaces, both inside and outside the property
boundary, and if visible proceed with Actions / Resolution.
MM RESPONSE: Revisions were made to the Dust Preventative Monitoring
Procedure to include visual observation of fugitive dust accumulation of the
downwind property boundary. However, we suggest that in D-1, a third bullet be
added stating: “or excessive accumulation of dust on surfaces if observed” to
assure that action will be taken if fugitive dust is observed at the site.
Additionally, we suggest that D-2 be revised to say “If D-1 conditions are
exceeded then:”. Also, “Actions if permit limits are exceeded” be replaced with
“Actions if D-1 limits are exceeded”. Accordingly, this item remains unresolved.
e. SOP for n-Butanol Odor Intensity Field Kit Requirements (pdf page 14 and 86)
iv. Require donning of 1/2 face carbon filter respirator prior to exiting the
odor free room and before making odor assessment.
MM RESPONSE: Information provided on pdf page 14 of the pdf
addresses use of the half face respirator from the controlled environment.
A correction on pdf page 86 noted the stock solution will be prepared “in
water”, not air. These items are considered resolved with the August 29
submission.
The process for removing sources that are the cause of truck complaints or odor
problems at the Dewatered Biosolids Receiving & Storage area or odors from
trucks during transit should be revised to address the above comments.
Accordingly, this item remains unresolved.
6. (pdf page 3) An intensity of 3.0 on the n-butanol scale has been accepted as a trigger for
certain response activities in the OCRP. Based on the history of odors complaints in the
community, we suggest the use of 3.0 to represent a “distinct odor” on the n-butanol scale be
reviewed annually. This review shall be coupled with an annual assessment of the entire
NMCP with Plainfield Township (Township) and Pen Argyl Borough (Borough) to review
records, complaints, operations, and emerging biosolids recycling science; to consider
modifications to improve the effectiveness of the overall SBHRC program.
MM RESPONSE: Information provided by Synagro in the August 29 revised NMCP is being
addressed with the commitment to participate in an annual meeting with the Township and
Boroughs. These items are considered resolved with the August 29 submission.
Additional Item: Storm Water Retention Pond Odors (pdf pages 28 and 29)
It has been brought to our attention that the on-site storm water retention pond at the SBHRC
could become a source of nuisance odors if eutrophic conditions develop in the basin. This is a
possibility, which could lead to off-site nuisance odor conditions. Accordingly, the applicant
shall revise the NMCP to include the retention pond as a potential source for nuisance odor
emissions and address appropriate related factors. This topic was discussed in the 7/23/19
conference call between MM and Synagro representatives, so it is not a new item, but is a new
element for the NMCP document, and needs to be addressed. As such, we currently consider this
item as unresolved at his time.
MM RESPONSE: “Odors from algae growth within sediment basin No.2” has been added as a
Risk and Hazard in the Housekeeping SOP. Additionally the Housekeeping SOP notes that
sediment basin No. 2 should be visually inspected at least once per week during the summer and
fall months and monthly in other months. We suggest that “should” be replaced with “shall”.
To insure that the sediment basin will be monitored for odors, it is also suggested that “and
sediment basin No. 2” be added to O-3 of the Odor Preventive Monitoring Procedure (pdf page
15). Accordingly, this item remains unresolved.
Annual Updates to the NMCP and Comprehensive Monitoring Program (pdf page 3)
It is understood that annual updates to the NMCP and Comprehensive Monitoring Program will
be implemented in the future, based on experience gained through time at the SBHRC and
advancing biosolids science. If certain aspects of the NMCP and/or the Comprehensive
Monitoring Program are found to be lacking, annual updates will fill this void, making the
NMCP a true “Living Document”. Incorporating plans to hold an annual meeting with Plainfield
Township and Pen Argyl Borough into the NMCP is the best way to share accomplishments and
ideas for the upcoming year.
MM RESPONSE: This item is considered resolved with the August 29 submission.
Should you have any questions about comments provided herein, please contact me at (717) 367-
9697 or trudy@materialmatters.com.
Trudy Johnston
CEO
September 4, 2019
1. Full compliance with all NMCP (as approved, adopted and amended) provisions and
protocols at all times.
3. If NMCP provisions and protocols, which include the use of Professional Odor Support
(POS), identify Slate Belt Heat Recovery Facility (SBHRC) Facility or Site as the source
of malodors/nuisance odors and there continues to be ongoing malodor/nuisance odor
conditions caused by the Facility, SBHRC will voluntarily incur penalties and shut down
operations under the following conditions:
3.1. That the POS confirms the source of the nuisance odor conditions is emanating
from the SBHRC Facility and/or Site.
3.2. That the pre-Corrective Action Plan (CAP) efforts made in accordance with the
provisions and procedures set forth in the NMCP by SBHRC personnel to address the
ongoing odors has not resolved the malodor/nuisance odor conditions.
3.3. In the event that the remedies prescribed within the pre-CAP do not abate the
ongoing occurrence of malodors/nuisance odors emanating from SBHRC Facility or Site
and the NMCP CAP is scheduled to take longer than fifteen (15) days to implement, the
following temporary management efforts shall be employed in an effort to resolve, or
mitigate the malodor/nuisance odor conditions during this CAP implementation period:
i. Reduction in biosolids volume production throughput and output.
3.4. If completion of the CAP is scheduled to take longer than fifteen (15) calendar days
to implement, the following penalties shall be imposed for malodors/nuisance odors
and/or failure to implement enforcement provisions, and the penalties set forth below
1
shall accrue from the first day the SBHRC Facility or Site is identified as the source of
malodors or nuisance odors:
3.5. If CAP has not resolved identified malodors/nuisance odors after ninety (90) days,
then SBHRC shall cease operations on or before expiration of the ninetieth (90 th) day and
shall remain ceased until such time that the permanent CAP is implemented and all
permanent CAP work is completed and inspected. From time of plant cessation, SBHRC
has forty-eight (48) hours to complete processing all material in the receiving hopper and
thirty (30) days to remove from the Site all finished product stored in Facility silos and/or
hoppers.
3.6. SBHRC shall be allowed to restart the Facility after Synagro Corporate Engineering
Department (or any successor Department) has determined based on their technical
analysis and industry standards that the cause of the malodor/nuisance odor conditions
have been addressed.
3.7. Once the CAP is successfully implemented and all permanent CAP work is
completed and inspected and SBHRC is back in operation for seven (7) continuous days,
the POC will conduct a review to confirm that the problem has been mitigated. If the
POS determines that the malodors/nuisance odors have not been abated, the facility shall
again shut down in accordance with Section 3.5, with all relevant penalties as set forth in
Section 3.4 restarting from the “Over Ninety Calendar Days” time period.
2
1001 Lackawanna Trail
BCM
ENGINEERS
Clarks Summit, PA 18411
Phone: (570) 587-3339
Fax: (570) 586-7989
www.atcgroupservices.com
ATC GROUP SERVICES LLC
September 4,2019
Plainfield Township
6292 Sullivan Road
Nazareth, PA 18054
BCM Engineers/ATC Group Services (BCM) has reviewed the proposed Stormwater Monitoring
Plan, Sediment Basin No.2 Monitoring Plan, Groundwater Monitoring Plan, and Backfill
Sampling and Analysis Plan, as submitted with the letter of transmittal dated August 30, 2019,
from Mr. Thomas G. Pullar, P.E., EARTHRES.
The revised plans reflect changes agreed upon during the conference call held on August 29,
2019. Based upon our review, BCM believes monitoring of the Stormwater Outfalls, Sediment
Basin No.2, and Groundwater, as proposed in the revised plans, provides for an effective means
to monitor stOimwater discharges from the proposed facility.
BCM has also reviewed the email message from Mr. Pullar dated September 3,2019, stating that
PA DEP has "confirmed that a condition can be added to Section C of the NPDES Pelmit
referencing the Township Monitoring Plan." Plainfield Township should request clarification
regarding the following:
I. Is the proposal still that the NPDES permit condition will include the Stormwater
Monitoring Plan only, and that the Sediment Basin No.2 Monitoring Plan and the
Groundwater Monitoring Plan will be included under the GCSL landfill permit
modification?
2. If the answer to the above question is yes, Plainfield Township should be provided
fiuther details showing exactly how the Sediment Basin No.2 Monitoring Plan and the
Groundwater Monitoring Plan will be incorporated into the GCSL landfill permit.
3. Plainfield Township should be provided an opportunity to review and comment upon the
contemplated NPDES Pennit Section C language and any modifications to the GSCL
landfill pelmit.
1
BCM
ENGINEERS
ATC GROUP SERVICES LLC
Enclosures
cc: Phil F. Gray, Jr., P.G., BCM Engineers/ATC Group Services LLC
2
HanoverEngineering
252 Brodhead Road • Suite 100 • Bethlehem, PA 18017-8944
Phone: 610.691.5644 • Fax: 610.691.6968 • HanoverEng.com
September 6, 2019
We have completed our review of the revised submission materials from EarthRes Group, Inc.
received in our office on September 3, 2019, which included the following materials:
Based on our review, we offer the following comments, as related to wetlands, waters, and riparian
buffer impact concerns for the Township's consideration:
1. Per Section 22-1023.4.E. of the Township's Code of Ordinances, the on-site pond is
subject to the 50-foot open space buffer from the existing top of bank. Per Section 22-
1023.1. Purpose - It is the purpose of this Section to establish requirementsfor the establishment,
maintenance andpreseroation ofriparian buffers and open space, as defined herein, to protect the
watercourses, ponds, lakes and wetlands in Plainfield Townsh{b, and to limit the surface areas of buildings
and structures within these areas. Per Section 22-1023.3 ApplicabiJiry, Item A. - This Section shall applY
to all lands within Plainfield Township that are a4jacent to a watercourse. pond, lake or wetland. Per
Section 22-1023.3 AppJicabiliry, Item B. - This Section shall applY to alfJ subdivision or land develo,pment
vlan, submitted after the effective date ofthis Section. Per Section 22-1023.4. General Design Standards,
J. ... ~ :::
Item E. - All areas within 50 ftet ofthe top ofthe bank ofa'!Y pond or lake shall be open space.
Stormwater controlponds, not intended to permanentlY retain water, are not suo/ect to this requirement.
Envisioning and Engineering sustainable, cost-effective, and environmentally responsible projects since 1971
Mr. Thomas Petrucci 2 September 6, 2019
Township Manager
Based on the language presented in the Purpose and Applicability subsections, the intent of
Section 22-1023 is to protect existing wedands and "waters" within the Township. The
pond, identified as Sedimentation Basin No.2 on the Applicant's plans, is a modified old
quarry pond that has a demonstrated and accepted connection to groundwater and nearby
surface waters (through groundwater). The pond permanendy retains water based on
photographic evidence, testimony, and information provided by the Applicant. Additionally,
several fish were observed in the pond along the shoreline during a site visit conducted on
April 26, 2019, which would further support that this feature permanendy retains water.
This pond, while approved in the past for use to control stormwater from adjacent land uses,
does not function explicitly as a "sedimentation basin" and does not meet the design
standards as a sedimentation basin under Chapter 102, Title 25 of the Pennsylvania Code.
The pond also meets the common definition of a "pond" in both the Merriam-Webster and
Black's Law Dictionaries. This pond has been and will continue to be, as proposed, a
permanent surface water feature in the landscape that meets the definition(s) of a "pond"
and also provides certain stormwater control functions and permanently retains water. This
pond has been determined to be a "waters of the Commonwealth." Therefore, the
proposed project is not in compliance with the Township's ordinance, noting the proposed
significant encroachment into the 50-foot buffer area for filling and proposed structures and
facilities.
The recendy submitted Wedand and Riparian Buffer and Open Space Exhibit contains notes
indicating that "Sedimentation Basin #2 is not intended to permanendy retain water" and
that "No open space area is shown around Sedimentation Basin #2 on the existing
conditions plan, Sheet C-05 because the Township specifically decided to not apply such a
buffer during the proceedings for approval of the expansion which included the
reconfiguration of Sedimentation Basin #2 into its current form." As discussed above and
based on ample evidence and testimony, Sedimentation Basin #2 permanendy retains water
and therefore is subject to the Ordinance. Further, the Ordinance was approved by the
Township in 2013 and was not yet established when the prior approval was granted for the
landfill expansion in 2008. Per Section 22-1023.3. Applicabiliry, Item B. - This Section shall applY to
any subdivision or land development plan, submitted qfter the effective date (if/his Section. Therefore, the
Township'S 50-foot open space set-back/buffer is applicable to the existing pond, as
measured from its existing top of bank. This buffer must be shown on the plans. The
current plans are not in compliance with this section of the Ordinance. Regardless of the
Pennsylvania Department of Environmental Protection's (FA DEP's) grant of approvals or
permits for encroachments on the pond (e.g., proposed filling), the Applicant still must
obtain relief from the Township's Ordinance provisions.
such should be provided to the Township, which may be in the form of an approved minor
permit modification, as noted by the Applicant.
The proposed activities include the discharge of approximately 100,000 cubic yards of fill
material and stormwater (including associated structures) into the pond, identified as
Sediment Basin No.2 within the application materials. This pond has been determined to
be a "waters of the Commonwealth" and is connected to nearby streams and groundwater.
While the pond may serve certain functions for stormwater control, it is also a surface water
with connections to other surface waters and groundwater. Due to concerns for impacts to
water quality associated with the proposed substantial filling and the stormwater discharges,
the Township feels that a formal review of the proposed activities under Chapter 105 by the
PADEP is warranted.
4. Bog Turtle Clearance needs to be amended to include all wedands along Waltz Creek
that are within 300 feet of the proposed project disturbance area. On August 29, 2019,
Hanover Engineering corresponded with Mr. Robert Anderson of the United States Fish and
Wildlife Service (USFWS) regarding the previously noted concerns related to both wetlands
and bog turtle habitat evaluations provided for Township review. Mr. Anderson reviewed
data and information submitted by the Applicant's consultant for USFWS review and
classified USFWS database information related to bog turtle occurrence in the region, along
with information and photographs provided by Hanover Engineering. Mr. Anderson
concluded in an e-mail to Hanover Engineering that the wetland area along Waltz Creek was
"atypical bog turtle habitat" and that there is "no supporting evidence that bog turtles will be
impacted by the Slate Belt Heat Recovery Center project." This correspondence from
USFWS is sufficient to serve as clearance for the listed Potential Impact on the Pennsylvania
Natural Diversity Inventory (PNDI) Search Receipt for the proposed project.
5. Per Sections 22-1023.4.F. and 22-1023.8. of the Township's Code of Ordinances, all
wedands, waters, and riparian buffers (including open space buffers) must be shown
on the plans by bearings and distances with at least two ties to property comers. The
buffer on wedands can be shown as a dimensioned offset line.
The bearings and distances, with ties to property comers, have been added to the plans for
the on-site and adjacent wetlands and associated riparian buffers, as well as for the Waltz
Creek and its riparian buffer. The bearings and distances, with ties to property comers, have
been added to the plans for the proposed open space buffer around the proposed
reconfigured pond. The bearings and distances, with ties to property comers, for the
existing pond and associated 50-foot open space buffer have not been included on the plans.
As noted above in the response to Item 1, the Township's Ordinance applies to both ponds
and "stormwater control ponds, not intended to permanently retain water." The bearings
and distances, with ties to property corners, for the noted features and associated buffers
must be added to the plans to comply with the Township's Ordinances.
It was determined that the Little Bushkill Creek and its riparian buffer are further than 100
feet from the site, and therefore do not need to be shown on the plans.
6. A monitoring plan that ensures the best protection of on- and off-site surface water
and groundwater, as relating to the operation and maintenance of the proposed Slate
Belt Heat Recovery Center facilities, needs to be finalized to the satisfaction of the
Mr. Thomas Petrucci 4 September 6, 2019
Township Manager
Township. Sediment Basin No.2 is proposed to be filled with approximately 100,000 cubic
yards of fill material and is proposed to receive stormwater from the proposed Slate Belt
Heat Recovery Center facilities. These activities may result in impacts to water quality within
the basin, surrounding groundwater, and nearby streams. The Applicant has indicated that
only clean fill material will be used and will be properly tested in accordance with PA DEP's
Management of Fill guidance document (Document No. 258-2182-773). While the fill
material may meet the definition of "clean fill," the material may contain nutrients, organic
matter, and other constituents which contribute to eutrophication of the pond and
associated water quality impacts. Stormwater inputs may result in similar impacts. The
concerns are amplified with the basin having no regular surface outflow, a condition which
often· results in accumulation of nutrients, organic matter, and other constituents which may
lead to ongoing water quality and odor impacts and a need for management and mitigation.
Due to concerns for water quality impacts to the basin, surrounding groundwater, and
nearby streams, as well as eutrophication and associated potential odors, monitoring of the
basin should be conducted monthly during the growing season for nutrients and chlorophyll
a, in accordance with a monitoring plan that also includes management recommendations
and alternatives that will be implemented at identified, associated thresholds or Action
Levels. The Applicant should work with the Township to develop a satisfactory plan.
Monitoring at established frequencies should be conducted annually for the life of the
project, with reporting of monitoring results and implemented management activities
provided annually to the Township. See Comment 4 - Basin No.2 Monitoring from prior
comment letter dated April 15, 2019.
Also refer to the comments by BCM Engineers regarding surface water and groundwater
quality monitoring.
The proposed draft Sediment Basin No.2 Monitoring Plan included in the July 26, 2019 and
August 30, 2019 review materials contained only limited testing in comparison to what has
been discussed with BCM Engineers and Hanover Engineering in past meetings and
correspondence. The Target Quantitation Limits (TQLs) for parameters related to
eutrophication concerns (e.g., total phosphorus, nitrate-nitrogen, ammonia-nitrogen, and
total suspended solids) were generally sufficient. Additional parameters, including
chlorophyll a and total Kjeldahl nitrogen should be added at meaningful TQLs. Water
transparency, as measured with a Secchi Disk should also be included. Frequency for
monitoring should be monthly during the growing season, annually, for the life of the
project. Action Levels for chlorophyll a and total phosphorus should be established, with
management activities and alternatives specified. Monitoring should be conducted before,
during, and following construction (during regular operations) of the proposed facilities.
7. Per Section 22-1023.8. of the Township's Code of Ordinances, "All wetlands, waters,
and riparian buffers (including open space buffers) must be shown on the plans ... "
The wetland (and waters) delineation report refers to the on-site and off-site ponds as
"non-jurisdictional stormwater management basins," with no mention as also being
''waters of the Commonwealth." It has been determined by PA DEP that the on-site
pond is a ''waters of the Commonwealth," which should be included in the wetland
evaluation report and labeled accordingly on the project plans. Unless the wetland
consultant officially confirmed with PA DEP that the on-site pond is a "non-
jurisdictional stormwater management basin," this reference should be removed
from their report. If there is official confirmation from PA DEP, then that
confirmation should be provided to the Township. A copy of the revised wetlands
(and waters) report should be provided to the Township. A copy of the revised
wetlands (and waters) report must be provided to the Township. The Sediment Basin No.2
has been labeled as a "waters of the Commonwealth" on Plan Sheets C-04A and C-05, as
required, noting that there is still a discrepancy on the regulatory boundary of this feature per
Township Ordinance, as noted above in comment responses to Items 1 and 5.
If you have any question or require additional information, please contact the undersigned.
Respectfully,
HANOVER ENGINEERING
'-
jes:llb
5: \Projects\Mumcipal\PlamficldTwp\Plfl8-12-G rnndCentraiSanitaryLandfiliHeatRecovery\Wetlands\CoverLotter-PelrUcci-SlateBeltHeatRccoveryCentet-Review-2019-09-06.doc
cc: Mr. Robert J. Lynn, PE, CSI, Hanover Engineering Associates, Inc.
Mr. Farley F. Fry, PE, Hanover Engineering Associates, Inc.
HanoverEngineering
20 C Snyder Lane • Ephrata, PA 17522-9101
Phone: 717.721.7444· Fax: 717.721.7447· HanoverEng.com
July 11,2019
Via E-Mail
Mr. Thomas R. Petrucci, Township Manager RE: Grand Central Sanitary Landfill Heat Recovery
Plainfield Township Preliminary/Final Land Development
6292 Sullivan Trail Plan
Nazareth, PA 18064 Summary of Outstanding Comments
Hanover Project PLF18-12
We have completed our review of the revised submission package received in our office on July 3,
2019, as prepared by Earthres Group, Inc. Based on our review, we offer the following comments:
A. ENVIRONMENTAL CONCERNS
1. The Applicant should coordinate with and address any concerns or requirements of
Citizens Water.
The Applicant has indicated that this item will be addressed as part of the final land
development submission.
The Applicant has added water system details to the drawing; but, it is not clear if the
water system information shown on the drawings is satisfactory to Citizens Water.
The Applicant should provide a letter from Citizens Water indicating that the
proposed water service shown on the plans is acceptable. The Meter Pit detail on
Sheet C-l1 shows a two-inch (2") and six-inch (8") connections to the meter pit
while Sheet C-07 shows a single six-inch (6") pipe. Please clarify.
The drawings have been revised to consistendy show an 8" pipe on all drawings.
2. A fire hydrant detail is provided on the plan, but it is not clear where a fire hydrant
will be installed. Please clarify. The Applicant should solicit input from the Chief of
the Plainfield Fire Department regarding fire hydrant locations.
Envisioning and Engineering sustainable, cost-effective, and environmentally responsible projects since 1971
Mr. Thomas R. Petrucci, 2 July 11,2019
Plainfield Township
The Applicant has indicated that the fire hydrant and meter pit details will be
addressed as part of the final land development submission.
3. The Applicant should submit documentation that the proposed sewer service and
grinder pump are satisfactory to the Pen Argyl Municipal Authority.
The Applicant has indicated that this item will be addressed as part of the final land
development submission.
5. The applicant has provided cut sheets for the proposed trailer/tanker and the
conditional approval from the Passaic Valley Sewerage Commission to accept
wastewater from the Slate Belt Heat Recovery Center.
6. The Applicant has noted that the trucks hauling biosolids will be licensed, fully-
contained and tarped. The Applicant should provide examples of similar trucks
transporting biosolids through residential areas with an emphasis on primary sludge,
secondary sludge, primary/secondary blend and undigested sludge.
The applicant has verbally indicated that they have provided two (2) examples and
references where similar trucks are used to transport sewage sludge through
Mr. Thomas R. Petrucci, 3 July 11, 2019
Plainfield Township
The applicant has provided two references where similar trucks are used to transport
sewage sludge through residential areas. It is not clear if these references cover
transport of primary sludge, secondary sludge, primary/secondary blend and
undigested sludge. The applicant did not provide more detailed information
regarding possible acceptance of dairy biosolids other than the proposed SBHRC
will accept any biosolids that meet the acceptance criteria. The applicant did not
respond to comments regarding if dairy biosolids would be digested material, raw
manure or manure from unaerated holding tanks.
The applicant has not addressed the question regarding the dust and odor potential
from pellets derived from unstabilized sludge versus digested sludge.
8. Provide details on the proposed 5,000-gallon tank adjacent to the truck tipping area.
The proposed tank is labeled as a Stormwater Capture Tank but includes wash water
from the unloading/loading area.
The tank includes a vent to provide air while water levels drop during pumping and
will exhaust air when the tank is filling. Odor control is not provided for the exhaust
air. The Applicant should evaluate the need for odor control due the presence of
washwater from the unloading/loading area.
The tank appears to be equipped with one (1) pump. The pumping rate is not
provided. The Applicant should consider a duplex pumping system since this tank
will include wash water from the unloading/loading area. What actions will be
taken if the single pump fails?
The tank is 11 feet in diameter and does not include a fillet. Sludge solids from the
unloading area could accumulate on the flat bottom tank due to the diameter
depending on the rate of pumping. The pumping rate is not defined at this time.
The type of pump is not provided. Will the pump be a solid handling pump or a
grinder pump?
The cartridge carbon filters should be considered as part of the Township review of
the NMCP. Details regarding the tank and pumps should be provided. The
applicant should consider connecting the 5,000-gallon tank to the odor control
system.
We understand that the details regarding the tank andpumps are design
details. Based on the infonnation provided, it does not appear that the tank
has been connected to the odor control system. This item has not been
addressed andis further subject to the Material Matters review ofthe NMCP.
9. Will the process wastewater storage tank be equipped with a standalone odor control
system or will one (1) central odor control system serve the entire complex? If the
latter, will overhead ductwork be required to serve the process wastewater storage
tank.
The application to PA DEP indicates that a negative pressure head space will be
maintained in the covered process wastewater storage tank. Additional details
should be provided as part of the final land development submittal.
Mr. Thomas R. Petrucci, 5 July 11,2019
Plainfield Township
The Applicant provided some additional information and notes that air from the
head space will be conveyed to the odor control system. The Applicant should
provide information on how the air will be conveyed to the air control system since
the Process Water Storage tank is distant from the rest of the facilities.
The applicant notes that the storage tank head space will be connected to the odor
control system without providing any details. Odor control for this tank will be
evaluated by the Township as part of the review of the NMCP.
The applicant has not submitted the requested detailed information. The odor
control system will require further review when more detailed drawings are
submitted as part of the land development process.
We understand that the details regarding the tank andpumps are design
details. Based on the infonnation provided, it does not appear that the tank
has been connected to the odor control system. This item is further subject to
the Material Matters review ofthe NMCP.
10. A proposed pumping station is proposed near the storage tank. Please provide
details.
A plan has been provided, but with few details. Pipe sizes and the pumping rate
have not been provided. The plan indicates that one (1) pump will be provided but
shows that space is provided for a second pump. The Applicant should consider a
duplex pumping system to improve system reliability. What actions will be taken if
the single pump fails?
As previously noted, odor control for this tank will be evaluated by the Township as
part of the review of the NMCP. The applicant has not responded to comments on
the pump or provisions for a second pump as a backup.
The applicant has not submitted the requested detailed information. The odor
control system and pumping station will require further review when more detailed
drawings are submitted.
This item is further subject to the Material Matters review ofthe NMCP.
11. Provide information on the proposed wastewater connection to the storage silos.
The Plan shows three (3) connections to the tank. The pipes are not labeled, pipe
materials are not identified, flow arrows are not provided, and pipe diameters are not
indicated. A Fill Pipe Elevation is provided; but, it is not clear if this is associated
with the force main from the 5,000-gallon stormwater collection tank or associated
with force main from the Dryer Building. The Fill Pipe Elevation shows a six-inch
(6") pipe. The pump discharge pipe in the 5,000 tank is three inches (3"). The pipe
size for the pipe conveying process water from the Drying Building to the Process
Water Storage Tank is not provided. Please clarify.
The Applicant is providing a double walled tank for process water storage and leak
detection system under the tank. These features provide valuable security from
leaks. We recommend that force mains discharging to the tank discharge over the
top of the tank wall to further enhance the integrity of the storage tank by reducing
the number of wall penetrations. It appears that two (2) pipe penetrations can be
eliminated by discharging over top of the tank wall.
Profiles should be provided for three (3) pipes associated with the storage tanks.
Profiles are provided for other water and sewage lines. The three process water
pipes crossing the paved area are not shown the relocated storm sewer profile on
Sheet C-09.
A Tank plan should be provided for a for better understanding of pipe layout.
Bollards should be considered for protecting exposed pipes from nearby traffic areas.
The applicant has provided a written description that addresses some but not all of
the questions and drawings with details have not been provided.
See comment 12. In addition, the applicant has noted that Standard Operating
Procedures will be employed to minimize wash water and the odor potential of wash
water. We have not received a copy of the referenced Standard Operating
Procedures and reserve comment pending submittal of the Standard Operating
Procedures. The applicant has provided a brief verbal description of pumping
station components.
12. The Applicant provided process control information as part of the application to PA
DEP. Additional, more detailed information should be provided as part of the final
land development submission.
The applicant provided a response and cited General Permit Form 20 Equipment
and Process Description that had been submitted to PA DEP but did not provide a
date of the latest submittal and did not provide a copy of the document or provide
copies of any comments made by PA DEP. We reserve further comment pending
receipt of the Permit Form 20.
The finalpump station is not listed as an odor source on Fonn 20. This item
is finther subject to the Material Matters review ofthe NMCP.
13. The Emergency Contact list in the Contingency Plan submitted to PA DEP should
be modified. The list should be revised to list the Slate Belt Regional Police
Department instead of the Pen Argyl Police Department. Finally, the emergency
contact list should include emergency medical response services provided by the
Plainfield Township Volunteer Fire Company and Suburban Emergency Medical
Services.
14. The Applicant should provide assumed process wastewater characteristics and note
if the process wastewater storage tank will include solids withdrawal capability or
mixing capability.
The applicant has indicated that aeration and mixing will not be provided at this time
based the design concepts of a comparable belt type biosolids thermal dryer that
operates in a similar general arrangement. The applicant should provide the name
and contact information for the comparable installation.
B. ZONING - Items included under this section, as related to traffic, are subject to
further review by the Township Zoning Officer and Benchmark Civil Engineering
Services, Inc.
Mr. Thomas R. Petrucci, 8 July 11,2019
Plainfield Township
1. Section 27-410.5 - The proposed development does not appear to require a full
traffic impact study based on gross floor area or expected trip generation; however,
we have the following comments based on the provided truck turning exhibit and
general access configuration:
a. Several movements at the main facility access at the western end of site
appear to significandy encroach into opposing lanes. The western access
does not appear to be able to accommodate trucks passing in opposite
directions as they enter and exit the facility.
The applicant has not provided information regarding how truck traffic
conflicts will be resolved, whether they proposed development site or the
access road. The applicant's information addresses only turning movement
patterns and does not provide remedy for conflicts. Further, the provided
information is solely related to the Synagro Facility and does not consider
conflicts with traffic related to the other existing uses within the site. We
refer the applicant to Section 27-703.1.A,B, D and H.
b. Proper signage shall be provided for traffic pattern clarity and access use
restrictive, as necessary. Truck entrance access at the eastern driveway should
be prohibited.
Full signing and pavement marking plan and details shall be provided.
The applicant indicated that a signing and pavement marking plan will be
provided with the Final Plan.
c. The Applicant shall indicate how trucks will be staged if multiple trucks
arrive for loading and/or off loading at the same or similar times.
While the applicant has indicated staging of multiple trucks is not likely to
occur, does not adequately address what measures will be implemented if it
does occur. The potential for conflict within the SBHRC site as well as the
potential of conflict on the access road, should staging be necessary, should
be addressed.
d. The Applicant shall address how conflicts between truck movements and
passenger vehicles will be mitigated.
2. Section 27-41 0.5C(2) - The Applicant shall document, to the satisfaction of the
Zoning Officer, the existing access road is equivalent to a collector or major road
standards. Pavement markings may be required as recommended in the traffic
evaluation.
3. Section 27-410.5D(1) - The Applicant shall document all major roads and
intersections serving the project, including the access road and any primary
driveways or intersections.
4. Section 27-41 0.5D(2) - The Applicant shall document traffic circulation and update
the figures to include the site driveways. In addition, the evaluation shall document
traffic for employees, i.e. maintenance, operations, administrative, etc., other than
truck traffic.
6. Section 27-410.5D(4) - The Applicant shall update all analyses based upon the
turning movement counts and verify the opening year, as 2019 may be an overly
aggressive schedule.
7. Section 27-410.5D(5) - The Applicant shall document all site associated trips are
included and provide for any revised trip distribution for local trips not associated
with Route 33.
8. Section 27-410.5D(6) - The Applicant shall update all figures and analyses with data
obtained in the turning movement counts. Auxiliary lanes shall be evaluated for all
approaches and the signal warrant evaluations shall include all warrants applicable for
the intersections and driveways.
With regard to the December 28,2018 revised Access Study and the February 4, 2019 plan
submission, we defer to Benchmark Civil Engineering Services, Inc., Traffic Study review.
As noted herein, the need for a traffic impact study based on gross floor area or expected
trip generation is not met; however, we refer the applicant to Section 27-410.5 which
includes provisions for traffic impact assessment for any "truck terminal, or any sanitary
landfill, recycling, facility, material separation facility, composting facility, refuse derived fuel
facility or any solid waste transfer facility".
Mr. Thomas R. Petrucci, 10 July 11,2019
Plainfield Township
Evidence of Pen Argyl Municipal Authority review and approval of the sanitary
sewer design and details shall be provided prior to Final Plan approval by Plainfield
Township.
This item wiD be consideredresolved with the review and approval ofthe
design by Pen ArgylMunicipal Authority as part ofthe Final Plan review
process.
This item wiD be consideredresolved with the review and approval ofthe
design by PA American as part ofthe Final Plan reviewprocess.
This item wiD be consideredresolved with the review and approval ofthe
Erosion and Sedimentation Control Plan by Northampton County
Conservation District andissuance ofNPDES Permit/Modification by PA
DEP.
4. Section 22-503.11 - Construction details of sanitary sewer and water facilities shall
be in accordance with the respective service providers (PA American Water).
The applicant has indicated the PA American Water Details will be provided when
received.
This item wiD be consideredresolved with the review and approval ofthe
design by PA American as part ofthe Final Plan reviewprocess.
5. Section 22-504.2 - Certification ofPA American Water's public water supply shall be
provided prior to Final Plan review and approval by Plainfield Township.
Mr. Thomas R. Petrucci, 11 July 11,2019
Plainfield Township
This item wiD be consideredresolved with the review and approval ofthe
design by PA American as part ofthe Final Plan reviewprocess.
This item wiD be considered resolved with the review and approval ofthe
design by Pen Argyl Municipal Authority as part ofthe Final Plan review
process.
7. Section 22-504.8 - A Traffic Study shall be provided for all sanitary landfill,
recycling, material separation, composting, refuse derived fuel or solid waste transfer
facilities in accordance with Section 27-410.5 of the Code.
As noted herein, the Zoning Ordinance Section 27-410.5 does not require traffic
study for the proposed use based solely on gross floor area or trip generation and is
subject to Township Engineer determination; however, the Subdivision and Land
Development Ordinance requires a study for the proposed Materials Separation use.
Based on our review of the provided information, the lack of information regarding
the full use of the access road and access from Rt. 512 and the information included
in the Form 20 - Narrative associated with the Municipal or Residual Waste General
Permit application, we believe that a study is appropriate. The Applicant initially
indicated that the trucks delivering the sludge cakes to the processing facility would
also be hauling the waste-water back to the points of origin for processing; however,
the referenced narrative indicates that the wastewater may be removed from the site
by contracted haulers with the resultant combined truck traffic generated of 84
combined trips (42 trucks). The Applicant notes that the additional trucks will be
less than 12% of the approved 716 truck trips for GCSL but does not note the
existing traffic demand of the existing and proposed facilities.
8. Section 22-1003.4 - All aspects of the proposed land developments shall conform to
the Township Zoning Ordinance (Chapter 27) and all other Township Ordinances
and Specifications.
The Applicant has stated that the zoning permit application will be submitted after
land development approval is received, as included in the Plainfield Township
Zoning Officer's review.
This item wiD be consideredresolved with the review and approval ofthe
zoningpermit application by the Township Zoning OfBeer.
Mr. Thomas R. Petrucci, 12 July 11, 2019
Plainfield Township
The Applicant has acknowledged this requirement. The Applicant shall provide
evidence of compliance with all local, state and federal requirements prior to the
Township's consideration of the plan for approval.
10. Section 22-1 008.5.A - Requirements for recreation land area or fee-in-lieu of land
area shall be detennined by the Board of Supervisors.
The Applicant has indicated that this requirement will be addressed with the Board
of Supervisors.
D. STORMWATER MANAGEMENT
The Applicant has stated that the information will be provided with the revised plan
submission.
The applicant has provided calculations based on certain assumptions. Please refer
to Additional Comment 3, below.
The Applicant has noted the concern and stated that the information will be
provided with the revised plan submission.
Mr. Thomas R. Petrucci, 13 July 11, 2019
Plainfield Township
The applicant has included wheel stops and fencing on the latest plan and has
indicated no additional protective measures will be considered unless requested by
the Plainfield Township Board of Supervisors.
The Applicant has stated that the information will be addressed with the NPDES
Permit Application and provided with the revised plan submission. We have
reviewed the information submitted as part of the NPDES Permit Application and
there does not appear to be any analysis of the dewatering time and capabilities of
Sediment Basin 2 to dewater the increased runoff volume within the application
information.
This item has not been addressed. We also refer you to the Hanover letters dated
August 22,2018 and February 21,2019, from Jason E. Smith, PWS, regarding
wetlands, waters and riparian buffer impacts of the proposed development.
As the applicant has noted, this item is subject to additional review ofthe
providedgeologic analysis andresponse to Hanover's (Jason Smith's) and
BCM's previous comments.
The applicant has indicated that a copy of the final NPDES permit will be provided
to Plainfield Township upon issuance; however, the applicant should provide
evidence of application completion and any technical review comments received
form PA DEP. All revisions to the PCSM Plans, associated with NPDES review
comments (FA DEP (April 1, 2019, Technical Deficiencies letter) shall be provided
to Plainfield Township for review.
5. Section 22-10234.E - The on-site Pond/Sediment Basin No.2 is subject to the 50-
feet open space buffer from the existing top of bank. We refer the applicant to the
latest review letter from Jason Smith of Hanover Engineering for additional
discussion and information.
Mr. Thomas R. Petrucci, 14 July 11, 2019
Plainfield Township
The applicant has indicated that any Township requirements for landscaping and/or
fencing beyond what is included on the Preliminary Plan will be provided on the
Final Plan.
3. It appears that bypass stormwater runoff discharges into the Waltz Creek and Little
Bushkill Creek from new impervious areas without any effective water quality or
volume control BMPs. Specific concern is directed to the proposed access to Pen
Argyl Road, which includes new inlet connections to an existing conveyance that
discharges directly to Waltz Creek.
This item appears to have been addressed with the December 28, 2018 and February
4, 2019 plan review submissions, subject to PA DEP approval of the NPDES
Permit.
4. With the proposed increased basin bottom elevation (refer to limitations identified in
item 4, above) and the potential 20 vertical feet increase in basin bottom, the
applicant should verify that the assumptions related to the function/dewatering
abilities of the basin, as included on page 1 of 3 of the Sediment Basin No.2 analysis,
will remain valid.
E. GENERAL
1. The Township should consider the comments of the Township Zoning Officer.
3. The Township reserves the right to make additional comments based on the review
of revised submission materials.
4. Nothing included or excluded from this review relieves the Applicant from full
compliance with Township ordinances or any other Federal, State or Local
regulations.
Respectfully,
HANOVER ENGINEERING
Robert J. Lynn, P
rjl:fff/saf
S:\Municipal\Plainfield Township\2018\PLFI8-12 Grand Central Sanitary Landftll Heat Recovery\Grand Central Sanitary Landfdl Heat Recovery Plan Review 2019-07-
It.docx
September 6, 2019
Via E-Mail
Mr. Thomas R. Petrucci, Township Manager RE: Grand Central Sanitary Landfill Heat Recovery
Plainfield Township Preliminary/Final Land Development
6292 Sullivan Trail Plan
Nazareth, PA 18064 Summary of Outstanding Comments
Hanover Project PLF18-12
We have completed our review of the revised submission package received in our office on
September 3, 2019, as prepared by Earthres Group, Inc. Based on our review, we offer the following
comments:
A. ENVIRONMENTAL CONCERNS
1. The Applicant should coordinate with and address any concerns or requirements of
Citizens Water.
The Applicant has indicated that this item will be addressed as part of the Final Plan
submission, pending water service approval from PA American.
2. A fire hydrant detail is provided on the plan, but it is not clear where a fire hydrant
will be installed. Please clarify. The Applicant should solicit input from the Chief of
the Plainfield Fire Department regarding fire hydrant locations.
The Applicant has indicated that the fire hydrant and meter pit details will be
addressed as part of the Final Plan submission, pending water service approval from
PA American.
3. The Applicant should submit documentation that the proposed sewer service and
grinder pump are satisfactory to the Pen Argyl Municipal Authority.
The Applicant has indicated that this item will be addressed as part of the Final Plan
submission, pending sewer service extension approval from Pen Argyl Municipal
Authority.
Envisioning and Engineering sustainable, cost-effective, and environmentally responsible projects since 1971
Mr. Thomas R. Petrucci, 2 September 6, 2019
Plainfield Township
5. A proposed pumping station is proposed near the storage tank. Design details
should be provided as part of the Final Plan submittal.
Evidence of Pen Argyl Municipal Authority review and approval of the sanitary
sewer design and details shall be provided prior to Final Plan approval by Plainfield
Township. This item will be considered resolved with the review and approval of
the design by Pen Argyl Municipal Authority as part of the Final Plan review process.
4. Section 22-503.11 - Construction details of sanitary sewer and water facilities shall
be in accordance with the respective service providers (FA American Water).
The applicant has indicated the PA American Water Details will be provided when
received. This item will be considered resolved with the review and approval of the
design by PA American as part of the Final Plan review process.
Mr. Thomas R. Petrucci, 3 September 6, 2019
Plainfield Township
7. Section 22-1003.4 - All aspects of the proposed land developments shall conform to
the Township Zoning Ordinance (Chapter 27) and all other Township Ordinances
and Specifications. This item will be considered resolved with the review and
approval of the zoning permit application by the Township Zoning Officer.
The Applicant has acknowledged this requirement. The Applicant shall provide
evidence of compliance with all local, state and federal requirements prior to the
Township's consideration of the plan for approval.
This item will be considered resolved upon receipt of clean compliance reviews by all
Township professionals and receipt evidence that the applicable local, state and
federal agencies have reviewed and approved the various design and permitting
requirements of the proposed facilities.
The Applicant has indicated that this requirement will be addressed with the Board
of Supervisors.
C. STORMWATERMANAGEMENT
This item is subject to review and acceptance of the proposed monitoring and
sampling plan by Plainfield Township and PA DEP.
Mr. Thomas R. Petrucci, 4 September 6, 2019
Plainfield Township
The applicant has included wheel stops and fencing on the latest plan and has
indicated no additional protective measures will be considered unless requested by
the Plainfield Township Board of Supervisors. This item is subject to review and
determination by the Board of Supervisors.
As the applicant has noted, this item is subject to additional review of the provided
geologic analysis and response to Hanover's Gason Smith's) and BCM's previous
comments.
The applicant has indicated that a copy of the final NPDES permit will be provided
to Plainfield Township upon issuance; however, the applicant should provide
evidence of application completion and any technical review comments received
form PA DEP. All revisions to the PCSM Plans, associated with NPDES review
comments (pA DEP (April 1, 2019, Technical Deficiencies letter) shall be provided
to Plainfield Township for review, prior to Final Plan review and approval by
Plainfield Township.
5. Section 22-10234.E - The on-site Pond/Sediment Basin No.2 is subject to the 50-
feet open space buffer from the existing top of bank. We refer the applicant to the
latest review letter from Jason Smith of Hanover Engineering for additional
discussion and information.
This item is subject to additional review of the provided geologic analysis and
response to Hanover's Gason Smith's) previous comments.
The applicant has indicated that any Township requirements for landscaping and/or
fencing beyond what is included on the Preliminary Plan will be provided on the
Final Plan.
E. GENERAL
1. The Township should consider the comments of the Township Zoning Officer.
3. The Township reserves the right to make additional comments based on the review
of revised submission materials.
4. Nothing included or excluded from this review relieves the Applicant from full
compliance with Township ordinances or any other Federal, State or Local
regulations.
Respectfully,
HANOVER ENGINEERING
Robert J. Lynn, P ,
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S:\Projecl>\MunicipaJ\Plainficld Township\2018\PLF18-12 Grand Central Sanitary Landfill I-kat R<'Covcry\Grand Central Sanitary Landed] Heat Recovery Plan Review
2019-Sep.{)6.docx
RE: Review of Draft Plan Sets C-03, C-15 and C-17 last revised 8/13/2019 for the Grand
Central Sanitary Landfill, Inc. Slate Belt Heat Recovery Center Preliminary Land
Development/Major Subdivision Plan
Date: 8/29/2019
As requested, I have reviewed the draft plan sheets C-03, C-15 and C-17 for the Grand Central
Sanitary Landfill, Inc. Slate Belt Heat Recovery Center Preliminary Land
Development/Major Subdivision Plan. This memorandum is a direct follow-up to the email
you had sent me on August 21, 2019, in which you submitted the above-referenced plans in draft
form for the preliminary review and comment of Plainfield Township officials prior to a formal
submission of a revised final plan set.
1. Variance Required from Section §27-316 (2) (II) (2) ofthe Code of Ordinances of
Plainfield Township
Upon a review of the draft plan sheets C-03, C-15, and C-17, it is the opinion ofthe Zoning
Officer and I that a Variance is still required from Section §27-316 (2) (II) (2) ofthe Code
of Ordinances of Plainfield Township due to the fact that the proposed entrance and exit to
the facility are not located along an Arterial or Collector Road. Pursuant to the requirements
set forth in §27-316 (2) (II) (2), the proposed entrance and exit to the facility are not located
along either an Arterial or Collector road. The proposed entrance and exit to the facility are
located along an interior Private Access Drive of the Grand Central Sanitary Landfill.
Further, the entrance and exit to the facility of the proposed "Pen Argyl Road (S.R. 1011) Low-
Volume Driveway" are not separated or clearly designated. Further, the proposed entrance and
exit to the facility are not each at least thirty feet (30') in width; the driveway has a maximum
width of twenty-four feet (24').
The proposed "Pen Argyl Road (S.R. 1011) Low-Volume Driveway" is proposed to restrict truck
traffic. The Zoning Officer is of the opinion that a Low-Volume Driveway restricted to truck
traffic is not sufficient to serve the facility in accordance with the requirements of Section §27-
316 (2) (II) (2) of the Code of Ordinances of Plainfield Township. Section §27-3l6 (2) (II) (2)
requires that the entrance and exit to the facility be located along an Arterial or Collector Road; it
is the opinion of the Zoning Officer and I that said entrance and exit must allow for the activities
associated with the use to take place. A Low-Volume Driveway would not accommodate the
truck traffic that is associated with the proposed Material Separation Facility use.
I also directed the Township's Traffic Planning Consultant, who is Mr. Peter Terry, P.E. of
Benchmark Civil Engineering, Inc., to perform a review of draft plan sheets C-03, C-15, and C-
17. Mr. Terry's review letter dated August 29,2019, which identified technical deficiencies with
your submission, is enclosed and incorporated herein as though more fully set forth at length.
Please call me or email me if you have any questions or require additional information regarding
this matter.
Sincerely,
~_.
Thomas R. Petrucci
Township Manager/Secretary
Alternate Zoning Officer
Phone: 610-759-6944 ext 102
Email- manager@plainfieldtownship.org
Enclosure (Benchmark Civil Engineering, Inc. Review Letter Dated August 29, 2019)
TRP:trp
2
1727 Jonathan Street • Allentown, PA 18104
Phone: (610) 776-6700 • Fax: (610) 776-1190 • www.bencivil.com
Dear Tom:
As a follow up to your August 21, 2019 email, below please find our draft comments related to
Peter Spissak (Traffic Planning & Design, Inc.) August 19, 2019 email with Brian Boyer
(PennDOT 5-0 Permit Unit) and revised plans C-03, C-15, and C-17 prepared by EarthRes
Engineering last revised 8/13/19 which you provided with your email.
1. Plan sheet C-03 depicts a 74 foot wide driveway with what appears to be a pavement
marking at the center of the driveway. The driveway has a fifty foot deep throat length.
Brian Boyer confirms Peter Spissak’s August 19, 2019 email in which Brian indicates
that the proposed driveway would ultimately be approved given the following PennDOT
requirements:
A. Confirmation that adequate sight distance can be provided at the
intersection
B. The driveway would have a maximum width of 24 feet
C. The driveway radii would be 15 to 20 feet.
D. The applicant would provide as much shoulder widening as possible
without impacting the exiting utility poles for upt to 200 feet in either
direction from the driveway along Pen Argyl Road.
The driveway depicted on C-03 may satisfy item A above, however it does not satisfy
items B, C, or D.
Mr. Thomas R. Petrucci, Township Manager
Plainfield Township
Scoping App #S0520190014
Benchmark Project No. 671004 August 29, 2019
2. The email referenced above indicates that approval of the driveway would also need to
address truck restrictions. The plan C-03 indicates truck restriction signs on Pen Argyl
which face the eastbound and westbound Pen Argyl Road through traffic and are located
approximately fifty feet to the east and west of the proposed driveway. It is doubtful that
this is what Brian Boyer intended when he indicated the need for truck restrictions. The
signs would not provide proper notification to trucks on Pen Argyl Road approaching the
new intersection. It is more likely that Brian Boyer intended to limit the trucks using the
proposed driveway in which case a different sign arrangement would be necessary and
signs would be required both within the site and along Pen Argyl Road.
3. A plan should provided indicating the largest vehicle anticipated to use the proposed
driveway and that vehicles turning path. The plan should also depict whether that vehicle
can be accommodated on the existing pavement at the intersection and what pavement is
proposed to be constructed as part of the proposed driveway. This would also assist in
determining whether item 1.D above is addressed.
Sincerely,
-2-
Benchmark Civil Engineering Services, Inc. • 1727 Jonathan Street • Allentown, PA 18104 • Phone: (610) 776-6700 • www.bencivil.com